Operating since 1982, ACM Group Ltd (ACM) is a prominent Australian owned debt purchaser, with -its main focus on the finance, telecommunications and utilities sectors. The ACM head office is located in Sydney, with the company maintaining an offshore presence through operations based in Manilla. ACM employs around 260 full time employees.
Starting May 2012, the company undertook a formal review of its debt collection procedures in order to improve its processes and the broader compliance approach through a remediation strategy. We implemented a proactive plan that ensures all key activities comply with the laws governing the debt collection industry.
As part of our compliance commitment, in April 2013, ACM instigated frequent and regular meetings with the Credit Industry Ombudsman to ensure customer complaints are handled in a timely and efficient manner. Working with the CIO, rather than seeing compliance as something we have to do, really shifted our thinking.
In 2014 we continued to work with new OAIC privacy legislation and came up with innovative IT solutions requiring staff to internally register every customer contact. It’s an efficient and effective system that ensures ACM Group works within the regulatory guidelines and offers our customers peace of mind.
We analysed new ACCC/ASIC guidelines and updated our training accordingly, and by the end of July 2014, all existing and new staff had been up-skilled in these areas.
ACM have adopted a formal approach to managing compliance, which is represented through the identification of four components:
The identification of compliance obligations and the laws and regulations that apply to debt collection, and how ACM keeps itself informed of changes or updates to those obligations.
This relates to how obligations are communicated and applied across the company. This includes the systems and processes to support knowledge of the obligations, such as policies, procedures, work instructions and training.
A formal quality assessment (QA) process to ensure ongoing adherence is checked. In addition, system controls exist to ensure compliance against mandatory requirements.
The reinforcement of knowledge and learning gained through each stage of the framework. This is managed through a formal training process for new employees, and ongoing, through specific or targeted training based on identified need. These needs are then fed back into the other components to provide opportunities for improvement.
Provided each of the four components are managed appropriately, the framework provides a solid basis for development of an effective end to end compliance program.
A significant amount of ACM company material is continuously reviewed, including policy and procedure documentation, training content, collection strategy, collection processes, system controls, management controls, quality assessment, and audit controls in order to ensure that we are always improving our processes to maintain our position. This ensures we will be the leading debt collection organization in Australia as well as the largest privately owned Debt Acquisition company in Australia.
A review of ACM Group was undertaken by Tim Lord who was previously President of Dun and Bradstreet for 7 years andis now with Anteris Consulting. Mr Lord via Anteris Consulting was commissioned by ACCC to conduct a comprehensive review of the Australian Debt Collection Industry. Anteris consulting was given a free rein to conduct the areview of the entire ACM Group collection activities and procedures.
Anteris Consulting found that the Compliance Action Project had been effective, with ACM maintaining all of the standard compliance controls that would be expected of a company operating in the Debt Purchase market. It also found that ACM had particular strengths in relation to specific system controls that were recently introduced, as part of ACM’s significant effort in developing an active call audit process. Additionally, there was no evidence of any serious or obvious deficiencies, or any process requiring urgent remediation. The actual findings of his review can be found in the PDH file attached.
The adoption of the Kildonan training framework, providing the basis for ongoing engagement with customers, had particular relevance for customers who may be suffering from hardship of some form of vulnerability. The key principles of respect, active listening, and not judging in day-to-day activity has led to a significant decrease in complaints submitted to ACM Group.
ACM Group also uses a Quality Management System (ISO9001:2015) to provide the framework for documentation and management controls.
“We are actually feeling very positive and proud of what has been accomplished since 2012 to date”, said Trent Vieira, Director of Operations of ACM Group in Sydney. “There is an obvious commitment to ensuring ACM Group is conducting itself in a professional and compliant manner”, he added. There is no doubt that significant effort went into the development and implementation of these initiatives.
Like any other entity, we are aware there maybe other aspects of the compliance environment that could potentially benefit from further development and we are constantly working to ensure all of the fundamental systems and processes are in place to ensure compliance with regulatory requirements.